We have been reading your speech dated 15th October 2009, in which you seek to justify the Commission's policy of promoting GM crops and foods, and allowing the import of unauthorised GM soya in the face of the opposition of the majority of EU nation states and against the wishes of the majority of the people of Europe (1). Forgive us for saying so, but your attitude does not seem to show much respect for the democratic process, and it seems to be based on the very questionable assumption that you (as Commissioner) know more about the science of GM and about the commercial realities of the world than those whom you are supposed to represent. Your speech seems to have been aimed at the industrial / intensive farming sector, the WTO, the US free trade lobby, and the GM industry -- and seems to neglect entirely the interests of everybody else. And although you pretend that your strong feelings arise out of your respect for science, what we see when we read your words is a rather feeble sort of pragmatism and a Commission policy which has everything to do with politics and appeasement and nothing to do with science.

There are many points in your speech which are highly questionable, and which must be challenged. We will concentrate on just a few of them.

1. You suggest that we should all feel sorry for a dairy and intensive livestock rearing sector that has chosen to depend very largely upon imports of "cheap" (so long as environmental and socio- economic costs are excluded) soya from US, Brazil and Argentina. Why should we feel sorry for them? There are ample supplies of GM-free soya available on the world market, at perfectly reasonable prices, if importers choose to take advantage of them (2). You know, and we all know, that the US soy industry has been involved for years in the "contaminate by stealth" strategy, systematically allowing cross- contamination and slapdash handling procedures and making it virtually impossible to source genuinely GM-free soya from the US. That is why they have lost so much of the European market. The same is true of Argentina, and it is also happening in Paraguay. You pretend, in your speech, that if contaminated soy-based animal feed is passed as "clean" in the USA and is then blocked because of GM contamination in Europe, that is somehow Europe's fault. You actually say that "........the authorisation procedure had hit political resistance." You are implying that the good science is on the USA side of the Atlantic, and that "politics" is getting in the way in Europe. That is quite extraordinary, coming from a European Commissioner. You know full well that the EU system for vetting and approving GM is quite tight in Europe, with the full approval of national governments and the people of Europe. You also know that EFSA's opinions on GM safety are widely mistrusted, not just by environmental and consumer groups, but by many national governments as well (3). That is why EFSA has been urged, by almost everybody (including the Commission), to get its act together, and to make its decisions more transparent and scientifically more trustworthy. You appear here to be questioning the EU's own authorization and monitoring procedures as laid down in the Directives and Regulations -- and that is a very serious matter. On that basis, we ask you to consider whether your own position as Commission is still tenable.

2. You suggest that because GM contamination is occurring in US shipments of animal feed, and because we in Europe will have to depend more and more on US rather than Argentinian shipments in the future, we should simply go with the flow and re-designate contamination levels so as to suit the Americans and the animal feed exporters. That is, if we may say so, the most feeble sort of pragmatism, and is exactly what the GM corporations and the intensive farming lobby want. We never thought that we would witness a European Commissioner saying in effect "never mind the rules or the risks to public health and animal welfare -- let's just do what the seed traders and patent owners want." Let's be clear here -- if US feed shipments are contaminated with GM, the fault lies entirely with the American exporters and the appallingly lax American authorisation and monitoring procedures (4). This is THEIR problem, and their problem to put right. It is disingenuous and disloyal to pretend that somehow this is all Europe's fault.

3. Not for the first time, you flag up the term "asynchronous GM approvals" and refer to it as a "technical term" while implying again that somehow Europe is at fault for lagging behind "the rest of the world" in giving GM approvals. We are sorry to be blunt, but that is all a load of nonsense. The term was invented by the GM industry as a marketing stunt. it is almost as ludicrous as the terms " substantial equivalence" and "adventitious contamination". To talk about "asynchronous approvals" as if it is a problem is like complaining that my birthday is not on the same date as yours. Things are not synchronised in this world, and we would be living in an automated and authoritarian hell if they were. We all have to live with rules and regulations and laws that differ from country to country -- and it is disingenuous and absurd to pretend that others have got it right and we have got it wrong. In any case, we are NOT being left behind by the rest of the world. The great majority of the world is far behind the EU in the matter of GM authorisations -- not far ahead.

4. Another term you use in your speech is this: "..... a technical threshold for measurement." We cannot understand why you could not bring yourself to use the words that the rest of us would have used in the circumstances, but what you are talking about is increasing the permissible level of contamination in animal feed and maybe other food products to a higher level than 0.9%. The term "technical threshold" is nonsensical -- it is no more technical to allow contamination at 1.3% (or whatever) than it is to allow it at 0.9%. It is just lazier. Again, you fall back upon the feeble argument that because other countries use inadequate testing and GM identification procedures (in the case of the United States, quite deliberately), we in Europe should somehow fall in line and allow whatever contamination levels THEY might find acceptable. (There is nothing "technical" about the 0.9% contamination level either. That figure was dreamt up at the behest of the Commission by a group of scientists for political and pragmatic purposes -- it has no scientific justification.)

5. Most serioulsy of all, you seem to be intent upon an extraordinary and reprehensible misrepresentation of the science surrounding GM safety and environmental issues. Your apparent faith in the infallibility of EFSA judgements on GM health and safety issues is touching, especially since we are all aware that the Commission itself has been highly critical of the manner in which that body assesses evidence and tends to place the interests of GM applicants far above the interests of European consumers. We find many of your statements deeply worrying, and especially this passage: "Month after month, GMOs receive a clean bill of health from EFSA, but then get stuck because Member States cannot reach any qualified majority, in favour or against, when it comes to the vote on a proposal for authorisation. So first the relevant committee decides nothing; then the Council decides nothing; and finally, the Commission grants authorisation, as laid down in the rules. This process swallows huge amounts of time. That would be quite legitimate – necessary, in fact – if new scientific information was being put on the table. But in the vast majority of cases, this is not what’s happening." This is a grotesque misrepresentation of reality. You seem to think that EFSA does science, and that the nation states play politics. EFSA does bad science, based upon high-pressure advocacy from GM applicants, a lack of transparency, and an unwillingness either to commission independent health and safety research or to look seriously at independent research results that throw up "inconvenient" findings. EFSA has connived in "research blocking" which effectively means that the science in GM dossiers (manipulated and often fraudulent) is incapable of being replicated or peer reviewed (5). The system itself is scientifically unethical and therefore corrupt. The nation states are fully aware of this, and expressed their frustrations in the Environment Council meeting of December 2008 (6). For you to claim that the Commission and EFSA work on the basis of "science" while the nation states play politics and allow emotion or prejudice to colour their judgements is, quite frankly, bizarre.

We will appreciate a considered response to the points we raise in this letter. In the meantime, we trust that you will stop your campaign which is designed to dismantle the EU regulatory system for GM crops and foods just to appease a few multinational corporations and feed exporters.